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Privacy Policy

Last Updated: March 2023

Xflow Payments India Private Limited and its affiliates (together, Xflow) is committed to protecting the privacy of its customers and business partners. This privacy policy (“Privacy Policy”) seeks to help you understand what information we collect at Xflow, why we collect it, how we use it, including if and how we share the information with third parties, and the choices you have.

When we talk about “you” or “your” in this Privacy Policy, we are referring to the businesses who may use the dashboard, website or services (collectively, “Xflow Services”) provided by us from time to time, directly or through third party platforms integrated with Xflow Services. This Privacy Policy forms a part of the service agreement between you and Xflow for availing Xflow Services.

By availing Xflow Services and checking the acceptance box at the time of creating your account with us, you acknowledge and agree to the terms of this Privacy Policy, for the collection, processing, storage, use, disclosure, transfer and otherwise handling of your data including Personal Information and sensitive personal data or information (defined below) of your business representatives, directors, designated partners, other officers, beneficial owners and/or other individuals associated with your business in connection with the provision of Xflow Services (“Associated Individuals”) in accordance with the terms contained below.

If you do not wish to provide us with your personal information or sensitive personal data or information, please do not use the Xflow Services.

We may revise the Privacy Policy from time to time. We encourage you to check this page periodically for modifications or revisions to the Privacy Policy to understand how it affects the use of your information. We will not be responsible for your failure to remain informed about such changes.

“Personal information” shall mean any information that relates to a natural person, which, either directly or indirectly, in combination with other information, is capable of identifying such person.

“Sensitive personal data or information” or “SPI” shall mean personal information, which consists of information relating to any to the following of an individual:

a. passwords;

b. financial information such as bank account or credit card or debit card or other payment instrument details;

c. physical, physiological, and mental health condition;

d. sexual orientation;

e. medical records and history;

f. biometric information.

A. INFORMATION WE COLLECT AND RECEIVE

  1. Personal Information Collected from You The data that we collect from you may contain SPI or personal Information. The personal information which we will collect, store, use, process, and transfer may include but is not restricted to: name, gender, date of birth, father’s name, address, email IDs, PAN, phone numbers and other contact information of your Associated Individuals. We may also collect bank account details and details of other payment instruments (such as debit card/credit card information) belonging to you and your business associates, in connection with Xflow Services, which may be treated as personal information or SPI under applicable laws in some cases.

    We may also collect documents that may serve as proof of identity and address. We may extract any and all identifiers from these documents and use them for the Purposes mentioned below, in accordance with law. You are not required to provide your or any third party’s Aadhaar number for the use of our Xflow Services and the submission of your Aadhaar number is entirely voluntary.

    You must ensure that you have obtained the necessary consents and/or adhered to any other applicable legal requirements when sharing any personal information or SPI of your Associated Individuals with us.

  2. Other Information You Provide

  • Payment information: To enable our payment partners to accept and pay out money globally, and make global cross border payments, we will need to collect the financial information you provide for this purpose including your credit/debit card information, your bank account number, bank IFSC code etc. The information we collect would depend on the payment method that you use. We may pass this information on to our third-party payment services vendors and to our partners, or these entities may also directly collect this information from you.

  • Information from our partners: Our banks, licensed service providers or other financial institutions that we have tied up with, and/or third party vendors (such as identity verification agencies) may pass some of your information to us. We may also collect this information ourselves and pass some of this information on to them for processing.

  • Technical information: We may directly or through our third-party vendors collect your device IP address, browser configuration details, the date and time of access and use of Xflow Services, and analytics information about how you are accessing and using Xflow Services. We collect information that your browser or device sends whenever you visit or use Xflow Services. We may also collect technical information such as browser and network details for the purpose of identifying signals of fraud.

  • Cookies: We use cookies and similar technologies to record log data. We use both session-based and persistent cookies. Cookies are small text files sent by us to your computer and from your computer or mobile device to us each time you visit the Xflow Services. They are unique to your account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. Some cookies are associated with your account and personal information in order to remember that you are logged in and which accounts you are logged into. Other cookies are not tied to your account but are unique and allow us to carry out site analytics and customization, among other similar things.

  • Third party data: We may also receive information relating to you from third parties that we use to make our own information better or more useful. This might be aggregate level information or it might be more specific information.

  1. Review/ Opt-out

You have the right, upon request, to access and review the personal information provided by you. Upon discovering that the information provided is inaccurate or deficient in any manner, you may request us to make suitable changes or amendments to such information.

You have the option to refrain from disclosing your SPI to us. You will also have the option of withdrawing consent previously provided. However, exercising this option will impact our ability to provide you with any or all of the features and services of the Xflow Services.

B. PURPOSE OF COLLECTION

We may process information including SPI concerning you for the purposes mentioned below (the purposes above and contained below together Purposes).

  • To provide Xflow Services: Xflow will access and use your data as reasonably necessary and in accordance with your instructions to (a) provide, Xflow Services, including for the purpose of enabling cross-border payments on your behalf, for undertaking KYC/KYB verification in relation to your business, (b) prevent or address service, security, technical issues, or at your request in connection with support matters; (c) act in a manner required by law, (d) act in the manner expressly permitted in writing by you, and (d) offer you services incidental and ancillary to the provision of Xflow Services.

  • To improve our Xflow Services: We carry out research and analyze trends to better understand how Xflow Services are being utilized and to expand and improve them. We may use your information to make the Xflow Services serve you better.

  • To communicate with you:

  • Responding to your requests: If you contact us with a problem or question, we will use your information to respond.

  • Sending emails and notifications: By accepting the terms of this Privacy Policy you give us the permission to send you notifications and administrative emails and messages. You hereby consent to receiving communication from us. We may also contact you to inform you about changes in the Xflow Services, our offerings, and important Xflow Services related notices, such as security and fraud notices. These emails and notifications are considered part of the Xflow Services you may not opt-out of them. In addition, we sometimes send emails about new product features or other news about us.

  • Billing and account management: We use account data to administer accounts and keep track of billing and payments. We may use your account related information and other information available to us to process defaults.

  • Investigating and preventing misuse: We work hard to keep the Xflow Services secure and to prevent abuse and fraud and we may use any information from you for this purpose.

  • As required by law: We use information collected from you to comply with, as well as to enable our banks, payment service providers and other financial institutions to comply with obligations under law.

This Privacy Policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so it is no longer associated with an identifiable natural person.

C. RETENTION

The information we collect is retained in our servers, for such periods as required for providing the Xflow Services in accordance with our data retention policy.

We will not retain any SPI for longer than is required for the Purpose for which such data or information was collected, or may lawfully be used, or is otherwise required under any other law for the time being in force.

D. SHARING AND DISCLOSURE

We may disclose your personal information to others, if it is required to do so in order to facilitate use of the Xflow Services, or for the Purposes stated in this Privacy Policy. We will act on your behalf to enable you to provide your SPI to these third party financial institutions and other service providers. To the extent not specified in this Privacy Policy, any processing of your personal and SPI by such third parties will be governed by the terms of their privacy policies.

We may also disclose personal information with our employees, officers, agents, consultants, business associates, contractors, attorneys, etc., on a need to know basis for the Purposes.

We may also disclose and transfer your information to bona fide proposed investors from time to time.

Xflow will disclose any personal information if there is a legal requirement or if it is ordered to do so by a court of competent jurisdiction or to any government agency if required by law for the purposes of verification of identity, or for prevention, detection, or investigation of crime (including cyber incidents), or for prosecution or punishment of offences.

E. SECURITY

Xflow ensures the confidentiality and security of the personal information provided by you by implementing comprehensive information security practices and standards.

F. GRIEVANCE OFFICER

If you have any concerns or questions in relation to this Privacy Policy, you may address them to our grievance officer Ashwin Bhatnagar, at the email address: support@xflowpay.com.